door defense in Michigan

10 Michigan opinions name it 2 courts 1912–2021 1 in the last five years

The cases below were cited by Michigan courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (2)

Case	Followed	Cited
Miner v. Lormangreen mich · 1887 · cited in 2 Michigan opinions naming this issue, 2017–2017 2 sentences 2017See Miner v Lorman, 66 Mich 530, 532 ; 33 NW 866 (1887); Bishop, 140 Mich App at 726 ; Carbonnell, 114 Mich App at 221 ; Joba Const Co, Inc v Burns & Roe Inc, 121 Mich App 615, 636 ; 329 NW2d 760 (1982). 2017See Miner v Lorman, 66 Mich 530, 532 ; 33 NW 866 (1887); Bishop, 140 Mich App at 726 ; Carbonnell, 114 Mich App at 221 ; Joba Const Co, Inc v Burns & Roe Inc, 121 Mich App 615, 636 ; 329 NW2d 760 (1982).	2	2
People v. Stanawaygreen mich · 1994 · cited in 1 Michigan opinions naming this issue, 2018–2018 2 sentences 2018See generally People v. Stanaway , 446 Mich. 643 , 693, 521 N.W.2d 557 (1994) ("[A] prosecutor may not use an elicited denial as a springboard for introducing [otherwise inadmissible] substantive evidence under the guise of rebutting the denial.") (citation omitted). 2018See generally People v. Stanaway , 446 Mich. 643 , 693, 521 N.W.2d 557 (1994) ("[A] prosecutor may not use an elicited denial as a springboard for introducing [otherwise inadmissible] substantive evidence under the guise of rebutting the denial.") (citation omitted).	1	1

Distinguished, questioned or overruled (0)

Case	Negative	Cited
No negative-treatment citations attached to this issue in Michigan. Read the followed side critically anyway.

Also cited on this issue (10)

Case	Cited	Years
Bishop v. St John Hospital green michctapp · 1984 2 sentences 2017See Miner v Lorman, 66 Mich 530, 532 ; 33 NW 866 (1887); Bishop, 140 Mich App at 726 ; Carbonnell, 114 Mich App at 221 ; Joba Const Co, Inc v Burns & Roe Inc, 121 Mich App 615, 636 ; 329 NW2d 760 (1982). 2017See Miner v Lorman, 66 Mich 530, 532 ; 33 NW 866 (1887); Bishop, 140 Mich App at 726 ; Carbonnell, 114 Mich App at 221 ; Joba Const Co, Inc v Burns & Roe Inc, 121 Mich App 615, 636 ; 329 NW2d 760 (1982).	2	2017–2017
Joba Const. Co., Inc. v. Burns & Roe, Inc. green michctapp · 1982 2 sentences 2017See Miner v Lorman, 66 Mich 530, 532 ; 33 NW 866 (1887); Bishop, 140 Mich App at 726 ; Carbonnell, 114 Mich App at 221 ; Joba Const Co, Inc v Burns & Roe Inc, 121 Mich App 615, 636 ; 329 NW2d 760 (1982). 2017See Miner v Lorman, 66 Mich 530, 532 ; 33 NW 866 (1887); Bishop, 140 Mich App at 726 ; Carbonnell, 114 Mich App at 221 ; Joba Const Co, Inc v Burns & Roe Inc, 121 Mich App 615, 636 ; 329 NW2d 760 (1982).	2	2017–2017
Carbonell v. Bluhm green michctapp · 1982 2 sentences 2017See Miner v Lorman, 66 Mich 530, 532 ; 33 NW 866 (1887); Bishop, 140 Mich App at 726 ; Carbonnell, 114 Mich App at 221 ; Joba Const Co, Inc v Burns & Roe Inc, 121 Mich App 615, 636 ; 329 NW2d 760 (1982). 2017See Miner v Lorman, 66 Mich 530, 532 ; 33 NW 866 (1887); Bishop, 140 Mich App at 726 ; Carbonnell, 114 Mich App at 221 ; Joba Const Co, Inc v Burns & Roe Inc, 121 Mich App 615, 636 ; 329 NW2d 760 (1982).	2	2017–2017
People v Figgures green mich · 1996 1 sentence 2021After that, the prosecution was allowed to question Sweet on redirect regarding the allegations, Figgures, 451 Mich at 399-400 , and the other-acts evidence regarding the other allegations of sexual abuse was properly admitted.	1	2021–2021
People of Michigan v. Darrell John Wilder green mich · 2018 2 sentences 2018Id. at 67-68 . 3 We also rejected other arguments raised by defendant on appeal, but those issues are not pertinent to the issue decided by our Supreme Court or the issue now before this Court on remand from our Supreme Court. -4- Finally, our Supreme Court concluded that although “the prosecutor maintain[ed] that her second set of questions regarding defendant’s prior firearm convictions was appropriate to impeach the witness’s response to the first set of improper questions,” a party nonetheless “cannot seek to elicit inadmissible character evidence on cross-examination when the opposing par 2018Id. at 67-68 . 3 We also rejected other arguments raised by defendant on appeal, but those issues are not pertinent to the issue decided by our Supreme Court or the issue now before this Court on remand from our Supreme Court. -4- Finally, our Supreme Court concluded that although “the prosecutor maintain[ed] that her second set of questions regarding defendant’s prior firearm convictions was appropriate to impeach the witness’s response to the first set of improper questions,” a party nonetheless “cannot seek to elicit inadmissible character evidence on cross-examination when the opposing par	1	2018–2018
People v. Rosemary Gibson green michctapp · 1976 2 sentences 2015People v Gibson, 71 Mich App 543, 547 ; 248 NW2d 613 (1976). 2015People v Gibson, 71 Mich App 543, 547 ; 248 NW2d 613 (1976).	1	2015–2015
Bradley v. Mid-Century Insurance green mich · 1980 2 sentences 2003The next case to address the issue is Bradley v Mid-Century Ins Co, 409 Mich 1, 60-61 ; 294 NW2d 141 (1980). 2003The next case to address the issue is Bradley v Mid-Century Ins Co, 409 Mich 1, 60-61 ; 294 NW2d 141 (1980).	1	2003–2003
People v. Peabody neutral michctapp · 1971 2 sentences 1978However, I agree with the resolution that People v Peabody, 37 Mich App 87, 89-90 ; 194 NW2d 532 (1971), adopted to meet this situation: "To hold that a defendant’s lawyer opens the door by adverting to a defendant’s prior conviction record during direct examination would confront defendants and their lawyers with an unnecessary dilemma: whether to reveal a prior record on direct examination and thereby open the door to inquiry otherwise impermissible, or to leave it to the prosecutor to bring out the record for the first time on cross-examination. 1978However, I agree with the resolution that People v Peabody, 37 Mich App 87, 89-90 ; 194 NW2d 532 (1971), adopted to meet this situation: "To hold that a defendant’s lawyer opens the door by adverting to a defendant’s prior conviction record during direct examination would confront defendants and their lawyers with an unnecessary dilemma: whether to reveal a prior record on direct examination and thereby open the door to inquiry otherwise impermissible, or to leave it to the prosecutor to bring out the record for the first time on cross-examination.	1	1978–1978
People v. Eddington green michctapp · 1970 2 sentences 1971The defense did ask Detective Kennedy questions concerning the- three checks but as stated in People v. Eddington (1970), 23 Mich App 210 , 231: “A slight opening of the door by the defense should not permit the prosecution to swing it totally ajar.” As the case will be remanded for a new trial it is suggested that both the people and the defendant refrain from questions concerning the three checks not introduced into evidence. 1971The defense did ask Detective Kennedy questions concerning the three checks but as stated in People v. Eddington (1970), 23 Mich App 210 , 231: "A slight opening of the door by the defense should not permit the prosecution to swing it totally ajar." As the case will be remanded for a new trial it is suggested that both the people and the defendant refrain from questions concerning the three checks not introduced into evidence.	1	1971–1971
People v. Ecarius green mich · 1900 2 sentences 1912The judge in his charge emphasized the failure of the prosecution in that particular and did what he could to eliminate the subject from the deliberation of the jury. ‘ ‘ A failure to prove all that the prosecuting attorney, in his opening to the jury, in good faith stated he expected to prove, is not ground for reversal.” People v. Ecarius, 124 Mich. 616 ( 83 N. W. 628 ). /The prosecution was permitted to introduce testimony ''of two previous acts of misconduct between the same parties similar to the one relied on for conviction, in one of which a small dog figured as an interested spectator 1912The judge in his charge emphasized the failure of the prosecution in that particular and did what he could to eliminate the subject from the deliberation of the jury. ‘ ‘ A failure to prove all that the prosecuting attorney, in his opening to the jury, in good faith stated he expected to prove, is not ground for reversal.” People v. Ecarius, 124 Mich. 616 ( 83 N. W. 628 ). /The prosecution was permitted to introduce testimony ''of two previous acts of misconduct between the same parties similar to the one relied on for conviction, in one of which a small dog figured as an interested spectator	1	1912–1912

Statutes the citing opinions construe

MI § Mich. Comp. Laws § 769.26 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

NY 25 (1903–2024) NJ 24 (1953–2026) IL 13 (1930–2025) CA 12 (1920–2021) TX 12 (1945–2021) MD 11 (1946–2021) FL 11 (1990–2025) MI 10 (1912–2021) OH 10 (2005–2025) VA 10 (1990–2024) CT 10 (1977–2017) MS 8 (1978–2016) TN 7 (1944–2026) IN 7 (1970–2011) UT 7 (1983–2017) NC 7 (1989–2026) GA 6 (1979–2014) MT 6 (1984–2017) OK 6 (1926–2007) MO 6 (1900–2025) WA 6 (1914–2016) PA 6 (1937–2015) MA 5 (1940–2015) HI 5 (2019–2021) SD 4 (2002–2017) LA 4 (1939–2015) AZ 4 (1978–2023) WI 4 (1920–2018) CO 4 (1972–2010) ND 3 (2015–2024) IA 3 (1921–2023) AL 3 (1962–2008) WY 3 (1997–1999) MN 3 (1984–2003) KS 3 (1966–2018) DC 3 (1997–2019) OR 2 (1902–2017) AR 2 (1925–1960) NE 2 (1910–2016) NM 2 (1997–2009) WV 2 (1996–2017)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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